SW3240102_Response To Comments_20240501

April 26, 2024
April 30, 2024
Mc2 Engineering, Inc.
Attn: Jeff McCluskey, PE
2110 Ben Craig Drive, Suite 400
Charlotte,NC 28262
AND
Lane Creek Volunteer Fire Department
Attn: Chief Robert Sweatt
7608 Landsford Road
Monroe,NC 28112
Subject: Request for Additional Information
Stormwater Permit No. SW3240102
Lanes Creek Volunteer Fire Department
Union County
Dear Mr. McCluskey and Chief Sweatt:
The Division of Energy, Mineral and Land Resources (DEMLR), received a Stormwater
Management Permit Application for the subject project on January 31, 2024. A review of that
information has determined that the application is not complete. The following information is
needed to continue the stormwater review:
1. Please revise the Supplement EZ form.
a. Cover: Line 7, 8 —Per 15A NCAC 02H .1017 (10), the vegetated setback shall be at least
30 feet in width and remain vegetated.
Lines 7 and 8 have been filled in.
b. Drainage Areas Page—Please fill out the LD 1 column.
LD 1 column has been filled out.
c. Low Density Page—The Low Density Page of the Supplement-EZ was not provided and
could not be reviewed. Please generate the page by clicking "Load Supplement Forms"
after selecting "Low" as the project type on the cover page.
The low-density page is now provided.
2. Per the latest USGS topographic map, surface water exists adjacent to the project area.
Revise the package accordingly to provide vegetated setbacks if they fall within the
project per 15A NCAC 02H .1017 (10). Vegetated setbacks are measured horizontally
from the top of bank of each side of streams 15A NCAC 02H .1003 (4a). The minimum
vegetated setback must be 30 ft. An updated USGS sheet is now provided with the
outline of the site displayed. There are no jurisdictional streams on site and the site is
beyond the 30 ft. vegetation buffer required.

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3. The provided O&M Agreement Form appears to be missing the page outlining the
operation and maintenance requirements associated with this project. The additional
page should have been generated once the"Click to Update Manual" link was clicked on
the cover page (They will show up in a separate sheet called"Low Density"). Please
provide a hard copy and electronic copy of this page of the O&M Agreement Form. The
cover page will not need to be resubmitted. The O&M Agreement is required per 15A
NCAC 02H .1042 (2) (j).
A Copy of the "Low Density" sheet is now provided.
4. 15A NCAC 02H .1003(2)(b)—The proposed design does not maximize dispersed flow
through vegetated areas/minimize the channelization of flow. The runoff from the project
is channelized via a pipe network of roof drains. A low-density project would be
designed so that most, if not all of the runoff from proposed BUA is allowed to sheet
flow across vegetated areas as dispersed flow.
This statement is untrue. As shown with the drainage area for the entire project we have
an overall BUA of 20%. The existing impervious area, 1/2 of the new building and entire
proposed parking lot will utilize dispersed flow into the lawn areas. As previously
mentioned in phone conversations with Brianna the fire station has indicated that they
have had issues with runoff from behind the building flooding into the rear of the
building. With this information it was determined that the best course of action to
prevent flooding into the existing and proposed building was to install a minimal amount
of storm sewer to capture the runoff from the rear of building and the lawn/pasture area
to the rear of the building and then pipe it under the proposed parking lot since installing
a swale around the rear of the site wouldn't be possible to have enough fall at a
reasonable grade to properly drain that area and connect to the existing grades at the

front of the site. As indicated with the drainage area LD1 which consists of the storm
sewer from YI6-CV3 this drainage area is 19%BUA with 1528 sf of existing building,
1389 sf of proposed building and 621 sf of proposed sidewalk. Therefore, this drainage
area even though it is piped is still low density and will be utilizing vegetated swale at
the discharge as indicated with the calculations for Swale#1.
Please also note that the proposed re-development of the site is actually reducing the
impervious footprint of the site by removing 1,797 sf of gravel that currently exists. Per
the following code we are not required to install SCM since we meet the criteria within §
143-214.7. Stormwater runoff rules and programs.
(b3) Stormwater runoff rules and programs shall not require private property owners to install new
or increased stormwater controls for (i) preexisting development or (ii) redevelopment activities that do
not remove or decrease existing stormwater controls. When a preexisting development is redeveloped,
either in whole or in part, increased stormwater controls shall only be required for the amount of
impervious surface being created that exceeds the amount of impervious surface that existed before the
redevelopment. Provided, however, a property owner may voluntarily elect to treat all stormwater from
preexisting development or redevelopment activities described herein for the purpose of exceeding
allowable density under the applicable water supply watershed rules as provided in G.S. 143-214.5(d3).
This subsection applies to all local governments regardless of the source of their regulatory authority.
Local governments shall include the requirements of this subsection in their stormwater ordinances.
5. Provide engineering calculations demonstrating that stormwater outlets are designed so
that they do not cause erosion downslope of the discharge point during the peak flow
from the 10-year storm event per 15A NCAC 02H .1003 (5).
There will no longer be a culvert under the driveway since this has been re-designed
per NCDOT. The draining area flowing into the roof drain system YI6-CV3 has been
designed in the storm spreadsheet along with calculating the necessary channel matting
to prevent erosion at the outlet.
6. Please provide a Response to Comments letter indicating, in a point-by-point manner,
how each of the above comments has been addressed. This item is required per 15A
NCAC 02H .1042(3)(b).

7. Provide PDFs of all revisions, 2 hardcopies of revised plan sheets, 1 hardcopy of other
documents, and a response to comments letter briefly describing how the comments have
been addressed.
a. PDFs must be uploaded using the form at:
https://edocs.deq.nc.gov/Forms/SW-Supplemental-Upload
b. Hard copies must be mailed or delivered to the following address:
i. For FedEx/UPS:
Brianna Holland
512 N. Salisbury Street, Office 625Y
Raleigh,NC 27604
ii. For USPS:
Brianna Holland
1612 Mail Service Center
Raleigh,NC 27699-1612
iii. Hand Delivery:
Please reach out to me prior to hand delivering a submission to make sure that I
(or someone else in my group)will be able to receive the submission. Do not
leave the package in the foyer with the security guard.
NOTE: Hard copies should n91 be sent to a Regional Office. Doing so will delay
the review process and the submission package may be lost while being sent from
the Regional Office to me in the Central Office.
To ensure a fair, timely, and transparent review process, any disagreement with provided
comments will need to be addressed in writing as part of the requested information resubmission,
within the required resubmittal window. The merits of the disagreement will be reviewed during
the next scheduled technical review and, if applicable, will be addressed in further requests for
additional information. If the resolution provided by the reviewer is found to be unsatisfactory,
the applicant can agree in writing to a longer review period, during which the dispute will be
brought to the technical review committee and a final determination will be made.
Due to staffing limitations and to ensure an efficient project review, requests for individual
meetings to discuss provided comments are decided at the discretion of the reviewer. We
encourage you to carefully review the written feedback provided and the applicable rules. The
NCDEQ Stormwater Design Manual provides additional insight into design criteria. Any
questions or further requests for clarification should be submitted in writing in the requested
information resubmission, within the required resubmittal window. We appreciate your
understanding and cooperation in this streamlined process.
Please note that this request for additional information is in response to a preliminary review.
The requested information should be received by this Office prior to May 26, 2024, or the
application will be returned as incomplete. The return of a project will necessitate resubmittal
of all required items, including the application fee. Please reference the State assigned project
number SW3240102 on all correspondence.
If you need additional time to submit the information,please submit your request for a time
extension to the Division at the contact below. The request must indicate the date by which you

expect to submit the required information. The Division is allowed 90 days from the receipt of
a completed application to issue the permit.
The construction of any impervious surfaces, other than a construction entrance under an
approved Sedimentation Erosion Control Plan, is a violation of NCGS 143-215.1 and is subject
to enforcement action pursuant to NCGS 143-215.6A.
If you have any questions concerning this matter please feel free to contact me at
[e-mail] or(919) 707-9218.
Sincerely,
Brianna Holland
Environmental Engineer
DEMLR Post-Construction Stormwater Program
cc: Mooresville Regional Office